Purpose
Prove that recorded client entitlements agree with assets actually held and provide accurate, timely and sufficiently clear client reporting. Accurate reconciliation and record-keeping are essential to safeguarding client assets and supporting legal, regulatory, operational, and audit requirements.
Scope
Applies to all client money and virtual asset balances, transactions, records and client statements.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Reconcile internal records to external bank and wallet records at least weekly | Compare internal records with external bank and wallet statements to ensure reported balances accurately reflect assets held on behalf of clients. Increase frequency with scale and risk. | Reconciliation population, evidence and approval |
| 2 | Reconcile by asset, account or wallet, client entitlement, transaction and total holding | Ensure comprehensive reconciliation coverage across all dimensions. | Reconciliation breakdown by asset, account, wallet, entitlement and transaction |
| 3 | Investigate inconsistencies immediately and resolve without delay | Document corrective actions to ensure accountability and prevent recurrence. Document correction, root cause and preventive action. | Difference investigation, correction, root cause and remediation records |
| 4 | Escalate material or overdue differences and restrict affected movement | Where a safeguarding event overlaps with a sanctions, fraud, AML/CTF/CPF, cybersecurity, or operational incident, records must support cross-reference to the relevant escalation and remediation process. | Escalation and restriction records with cross-references |
| 5 | Maintain complete and auditable records | Cover client balances and entitlements; receipts, disbursements, and transfers; wallet addresses and payment instructions; authorization and approval records; holds, restrictions, reversals, and exceptions; reconciliation differences and resolution; linked compliance or safeguarding escalations. Full records for every transaction including receipts, disbursements, and current balances. | Complete client-asset transaction, balance, authorization, hold, exception and reconciliation records |
| 6 | Retain records for the minimum mandated period | Retain transaction, balance, location, authorization, hold, exception and reconciliation records for at least the minimum period mandated by applicable laws and regulations, and longer where necessary. | Records retention evidence |
| 7 | Prepare monthly statements | Show client money balances; virtual asset holdings; transactions conducted during the reporting period; and any interest earned or charges applied. Reports must be clear, accurate, and free from omissions or misleading information. | Monthly statements |
| 8 | Deliver statements to clients within 25 calendar days | Ensure clients have access to up-to-date information. Reporting process must align with applicable laws, regulations, and industry standards. | Statement delivery evidence (within 25 calendar days) |
| 9 | Investigate client-reported discrepancies promptly | Correct discrepancies and preserve corrected versions and communications. | Client discrepancy, correction and communication records |
Records
- Reconciliation population, evidence and approval
- Difference investigation, correction, root cause and remediation
- Complete client-asset transaction, balance, authorization, hold, exception and reconciliation records
- Monthly statements and delivery evidence (within 25 calendar days)
- Client discrepancy, correction and communication records
- Cross-references to linked compliance or safeguarding escalations
Relationships
- Policy: POL-SAFU-001 Client Asset Protection and Safeguarding Manual
- Process: PRC-CPO-001 Client Protection and Operations
- Control: CTRL-SAFU-004 Ensure Client Assets Are Reconciled and Reported Accurately
History
- 2026-07-26: Created from sections 6-7 and 18 of the approved SAFU Manual.